Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Extended period of limitation - it is found that appellant were under the bonafide belief that no service tax was payable on the brokerage received by them for providing steamer agent service being a sub-agent - also, all the transactions between the appellant and M/s. Freight Connection India Pvt. Limited are recorded in the books of accounts - extended time to demand service tax under Section 73 is not invokable. - AT
Extended period of limitation - it is found that appellant were under the bonafide belief that no service tax was payable on the brokerage received by them for providing steamer agent service being a sub-agent - also, all the transactions between the appellant and M/s. Freight Connection India Pvt. Limited are recorded in the books of accounts - extended time to demand service tax under Section 73 is not invokable. - AT
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